The Digital Operational Resilience Act (DORA) is now live across the EU, effective January 2025, and it has fundamentally changed how insurance companies must handle ICT risk, incident reporting, and third-party oversight.
DORA’s message is simple: resilience is the new compliance. Insurers can’t just show documentation anymore, they must prove their systems, teams, and vendors can withstand and recover from disruption.
This matters because insurers depend on intricate ICT environments for claims management, actuarial modelling, customer portals, and cross-border operations. One outage or vendor failure can disrupt thousands of customers within hours.
At Copla, we help insurers translate DORA’s legal requirements into practical workflows, using automation and expert guidance to make resilience part of daily operations.
You can read the full legislative text here: Digital Operational Resilience Act (EU) 2022/2554 on EUR-Lex.
What the DORA insurance regulation is
The DORA insurance regulation is part of the EU’s effort to strengthen digital resilience in the financial system. It requires insurers to demonstrate that they can withstand, respond to, and recover from ICT-related incidents—whether those stem from cyberattacks, internal system failures, or third-party disruptions.
Insurers are particularly exposed because they handle sensitive personal and financial data, operate real-time systems, and depend on interconnected digital supply chains. Under DORA, a system failure isn’t just a technical problem—it’s a regulatory one.
While frameworks like Solvency II focus on capital adequacy, DORA introduces a new lens: operational resilience. It measures how well your systems perform when things go wrong, not just how compliant your documentation looks on paper.
Key DORA insurance requirements
1. Implementation timeline and RTS updates
DORA took effect in January 2025, but the Regulatory Technical Standards (RTS)—the detailed implementation rules—are being released in phases throughout 2025. These RTS explain exactly how insurers must report incidents, test systems, and maintain their ICT registers.
Staying aligned with these RTS is not optional. Insurers need to monitor updates from the European Supervisory Authorities (ESAs), including EIOPA, which oversees insurance-specific implementation.
2. Incident reporting obligations
Incident reporting is one of the most visible changes under DORA. Insurers must:
- Detect and classify ICT-related incidents promptly.
- Report major incidents to regulators within strict time limits.
- Use harmonised templates that allow for EU-wide comparability.
This standardisation reduces reporting fragmentation but also raises the bar. Insurers must strengthen detection, monitoring, and internal communication processes to meet these tight deadlines.
3. ICT risk governance and resilience testing
Under DORA, ICT risk becomes a board-level issue. Senior leadership is expected to take accountability for resilience, not delegate it to technical teams.
Insurers must:
- Integrate ICT risk into corporate governance and decision-making.
- Conduct regular resilience testing of critical systems.
- Simulate realistic cyberattacks, outages, and data loss scenarios.
For insurers, where policyholder confidence depends on service continuity, resilience testing is both a regulatory requirement and a business necessity.
4. Outsourcing and subcontracting oversight
Insurers frequently rely on external ICT providers for claims management, analytics, and infrastructure. DORA makes it clear that you can outsource services, but not responsibility.
You must:
- Define clear contractual roles and responsibilities.
- Extend oversight to subcontractors, not just direct vendors.
- Establish exit strategies for all critical ICT relationships.
This requirement forces insurers to build full visibility into their digital supply chain. At Copla, our DORA Register Handler helps automate this by mapping providers and subcontractors into a regulator-ready format.
5. Register of information
Every insurer must maintain a Register of Information that details all ICT systems, providers, and dependencies. The RTS require this register to follow standard formats such as XML or CSV, enabling regulators to compare data across entities.
For large insurers with multiple subsidiaries and vendors, this is a major task. Automating register creation and maintenance is the only sustainable approach.
6. Exemptions for ancillary intermediaries
Certain ancillary insurance intermediaries, such as companies selling small travel or rental insurance add-ons, may fall outside DORA’s direct scope. However, mainstream insurers and their ICT providers are fully covered by the regulation and must comply in full.
How insurers can prepare
Common challenges
Most insurers face similar roadblocks when implementing DORA:
- Mapping critical ICT systems across regions and business units.
- Managing vendor and subcontractor risk in complex outsourcing chains.
- Balancing DORA with existing regulations such as Solvency II or GDPR.
Practical steps
Here’s how to move from planning to action:
- Conduct a DORA gap analysis. Identify overlaps and gaps between your existing ICT risk framework and DORA’s new requirements.
- Develop an incident playbook. Define escalation paths, responsibilities, and communication steps.
- Enhance vendor oversight. Update contracts to include DORA-aligned clauses and set up monitoring for critical providers.
- Automate compliance. Use software workflows to maintain ICT registers, manage reporting, and stay audit-ready.
These steps reduce manual work while proving to regulators that your resilience framework is both structured and proactive.
Tools to simplify compliance and resilience
At Copla, we see compliance as a foundation for resilience. Our micro-tools are designed to make DORA implementation easier for insurers.
- DORA Register Handler: Automates register creation and ensures compliance with XML/CSV standards.
- Incident Workflow Manager: Guides your teams through DORA-compliant reporting in real time.
These tools help insurers save time, reduce errors, and maintain audit readiness without turning compliance into an administrative burden.
For context, you can refer to the European Insurance and Occupational Pensions Authority (EIOPA) DORA page, which provides official guidance tailored to insurers.
Why DORA is a resilience opportunity
The DORA insurance regulation is more than another compliance box to tick. It represents a shift toward resilience-first operations across the insurance sector.
By meeting DORA’s requirements, insurers can:
- Minimise downtime during ICT disruptions.
- Strengthen customer trust and retention.
- Improve vendor accountability and transparency.
The insurers that act early, automate intelligently, and embed resilience into daily workflows will not only stay compliant but also gain a lasting competitive edge.
Copla helps make that possible by turning regulatory complexity into simple, repeatable, and resilient operations that strengthen both compliance and customer trust.
